UK Stewardship Code COBS 2.2.3R of the FCA’s Conduct of Business Sourcebook requires Promeritum Investment Management LLP (“Promeritum”, or the “Firm”) to disclose clearly on its website the nature of its commitment to the Financial Reporting Council’s Stewardship Code (the “Code”).
The Code was first published by the FRC in July 2010, then updated in September 2012, and then subsequently the FRC published a new UK Stewardship Code 2020 which took effect from the 1 January 2021. The code is a voluntary code and sets out a number of principles aiming to enhance engagement between institutional investors (including both fund managers and asset owners) and companies.
The FRC defines ‘stewardship’ as ‘the responsible allocation, management and oversight of capital to create long-term value for clients and beneficiaries leading to sustainable benefits for the economy, the environment and society.’
The twelve principles of the 2020 Code for asset managers are:
Purpose and governance
1. Signatories’ purpose, investment beliefs, strategy, and culture enable stewardship that creates long term value for clients and beneficiaries leading to sustainable benefits for the economy, the environment and society.
2. Signatories’ governance, resources and incentives support stewardship
3. Signatories manage conflicts of interest to put the best interests of clients and beneficiaries first.
4. Signatories identify and respond to market-wide and systemic risks to promote a well- functioning financial system.
5. Signatories review their policies, assure their processes and assess the effectiveness of their activities
6. Signatories take account of client and beneficiary needs and communicate the activities and outcomes of their stewardship and investment to them.
7. Signatories systematically integrate stewardship and investment, including material environmental, social and governance issues, and climate change, to fulfil their responsibilities.
8. Signatories monitor and hold to account managers and/or service providers.
9. Signatories engage with issuers to maintain or enhance the value of assets.
10. Signatories, where necessary, participate in collaborative engagement to influence issuers.
11. Signatories, where necessary, escalate stewardship activities to influence issuers.
Exercising rights and responsibilities
12. Signatories actively exercise their rights and responsibilities.
Promeritum pursues a fixed income strategy with a focus on emerging markets. Since the Firm’s strategy does not generally involve investing in the shares of companies, the Code has a limited application to its investment activities.
Promeritum has a voting policy in place, which sets out the circumstances and manner in which the Firm will vote on behalf of clients. The Firm also has a conflicts of interest policy in place to identify the risk of any conflicts of interest arising with or between its clients and has in place procedures to deal with any conflicts that may arise. These policies and procedures are regularly reviewed and updated.
In the event there were concerns regarding governance which might affect the value of its investments, the Firm would consider the most appropriate course of action including exercising its voting power to oppose the board and/or disposing of its investment.
While the Firm generally supports the objectives that underlie the Code, the Firm does not consider it appropriate to commit to adhering to the Code at this time. If the Firm’s investment strategy changes such the provisions of the Code become relevant, the Firm will review and if necessary amend this disclosure accordingly.